Equal Employment Opportunity (EEO) Policy

Last Updated: 24 April 2025

  1. Our Commitment

    Nocturnal Capital Partners is committed to fostering a diverse, inclusive, and respectful workplace. We believe that attracting and retaining talent from diverse backgrounds enhances our strategic perspective and strengthens our ability to deliver exceptional results for our investors.

  2. Equal Opportunity Principle

    We provide equal employment opportunities to all qualified individuals without regard to race, colour, religion, national origin, sex, age, disability, marital status, sexual orientation, gender identity, or any other characteristic protected by applicable Swiss law.

    Employment decisions, including recruitment, hiring, compensation, promotion, training, and termination, are based solely on merit, qualifications, and business needs.

  3. Scope and Application

    This policy applies to all aspects of employment, including:

    • Recruitment and selection processes

    • Compensation and benefits

    • Training and professional development

    • Promotion and advancement opportunities

    • Workplace conditions and facilities

    • Disciplinary actions and termination

  4. Non-Discrimination and Anti-Harassment

    4.1 Nocturnal Capital Partners maintains a zero-tolerance policy toward discrimination, harassment, and retaliation. This includes:

    • Unwelcome conduct based on protected characteristics

    • Sexual harassment or inappropriate behaviour

    • Retaliation against individuals who report concerns

    • Creation of a hostile work environment

    4.2 All employees are expected to contribute to a professional environment where individuals are treated with dignity and respect.

  5. Recruitment and Selection

    We employ structured recruitment processes designed to identify the most qualified candidates while minimising unconscious bias. Our approach includes:

    • Clear, objective selection criteria aligned with role requirements

    • Diverse interview panels where practicable

    • Reasonable accommodations for applicants with disabilities

    • Skills-based assessment methods

  6. Professional Development

    We provide equitable access to professional development opportunities, including:

    • Training programs to enhance technical and leadership capabilities

    • Mentorship and sponsorship initiatives

    • Internal mobility and advancement pathways

    • Performance feedback and career planning

  7. Reasonable Accommodations

    Nocturnal Capital Partners provides reasonable accommodations to qualified individuals with disabilities, and for religious observances, where such accommodations do not impose undue hardship on business operations.

  8. Reporting and Resolution

    8.1 Employees who experience or witness behaviour contrary to this policy are encouraged to report their concerns through:

    • Their direct manager

    • Human Resources

    • Designated compliance officers

    8.2 All reports will be treated confidentially and investigated promptly and impartially.

    8.3 Retaliation against individuals who report concerns in good faith is strictly prohibited and will result in disciplinary action.

  9. Responsibilities

    9.1 Management Responsibility

    Senior leadership is responsible for implementing this policy and ensuring their teams understand and comply with these standards.

    9.2 Employee Responsibility

    All employees are expected to uphold these principles in their daily interactions and professional conduct.

  10. Legal Compliance

    This policy aligns with Swiss employment law, including:

    • Swiss Federal Constitution (Article 8)

    • Gender Equality Act (GEA)

    • Disability Discrimination Act

    • Other applicable cantonal regulations

  11. Policy Administration

    This policy is administered by Human Resources in coordination with senior management. It will be reviewed annually and updated as necessary to reflect legal developments and best practices.

  12. Contact

    For questions about this policy or to report concerns, please contact:

    Human Resources

    hr@nocturnalpe.com

This policy represents our general principles and does not create contractual rights or modify the at-will nature of employment where applicable.